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Lanteigne re: nuclear waste dump planned by Lake Huron

View my power point to learn about the hazards of the proposed nuclear waste dump by Lake Huron and visit http://saveoursaugeenshores.org/
The Joint Panel EA review of Ontario Power Generation's proposed Deep Geological Repository at the shores of Lake Huron case 06-5-17520 is now under review. Send your emailed comments to DGR.Review@ceaa-acee.gc.ca. The more people speak up the better!

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Land-Use PlanningTraditionally, the underlying belief of planning is thatcollective rationality can be brought into the way ourcities are built rather than leaving it up to individualsin the marketplace where inefficiencies may prevailespecially with respect to long-term thinking(Makuch, 2004).

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Land-Use Planning And Private Development BiasPlanning is a highly charged financial process -development or redevelopment can mean big bucksfor private individuals.Private interests may have deleterious implicationsdespite the benefits they may bring about and thusmust be reconciled with the interests that the publichas for appropriate development that takes intoconsideration other values such as environmentalprotection and not overburdening municipal services(Swaigen, 1993).

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What Needs To Be AddressedThe technology, laws and regulations, and practicesfor containing, responding to and cleaning up spillslag behind the real risks and associated costs.

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Many Leaks Have HappenedUS based nuclear sites have suffered more than 400 accidental radioactive leaks during their history.Source: Union of Concerned Scientists. September 2011http://www.ucsusa.org/nuclear_power/nuclear_power_risk/safety/nrc-and-nuclear-power-safety-annual.html

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Remediation Can Be Very ExpensiveThe new price tag for completing the remainder of Hanford nuclear reservation cleanup, plus some post- cleanup oversight, is $112 billion. Source: The Tri-City Herald article New Cost for Hanford Clean Up by Annette Car Feb. 9 2012 http://www.mcclatchydc.com/2012/02/09/138402/new-estimate-of-hanford-cleanup.html#storylink=cpy

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Is Remediation Even Possible?Many contaminated aquifers cannot not be reclaimedbecause fixing the damage is “too costly” or “technicallyinfeasible.”

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Complacency To Monitoring Poses Risks Its assumed that the monitoring rules and requirements are in place and are protective but nobody knows for sure unless someone gets sick or complaints are issued.

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First Nations Paid the Price for Ontarios Lack ofReasonable Monitoring regarding Mercury Dumping58.7% of Grassy Narrows and White Dog FirstNations people have been poisoned by Mercury.33.7% have been diagnosed with Minimata Disease. Contamination violated Aboriginal Treaty Rights.

11.
Long Term Data is LackingOnce waste is underground, there are few ways to track howfar it goes, how quickly or where it winds up. There is plenty oftheory, but little long term data to prove how well thesesystems actually works. Bedrock aquifers and bedrockfractures exist but risks of these are often underestimated.

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Unreasonable economic burdenThe actual costs to monitor and maintain long termnuclear storage for the required 10,000 to millions ofyears, needs to be based on sound science and areasonable economic model to insure funding will bethere to complete the set tasks to avert public risksfor future generations.Is the financial scheme to support this project, based oncurrent proven need or is this based on projected needsanalysis on the premise that Ontario will actually want touse nuclear power in the future?

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Current Cost of Power per Kilowatt Hour in Ontario Source: Brochure titled Lets Cut Some Real Wastes as published by Ontario Clean Air Alliance, theCanadian Association of Physicians for the Environment & Canadian Federation of Students-Ontario.Energy conservation and efficiency: 2.3 to 4.6 centsWater power imports from Quebec: 5.8 centsWind : 11.5 centsNuclear – new and re-build 19-37 cents* *These numbers do not include the costs of decommissioningold reactors, long term storage of wastes or risks of accidents.For further information view: Toronto Star, Nuclear power too costly, Ontario Clean Air Alliance argues, JohnSpears, Business Reporter March 20 2012http://www.thestar.com/business/article/1149273--nuclear-power-too-costly-ontario-clean-air-alliance-argues

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Data Modelling can indicate that injectatewould be confined in the injection zone, but the reality of the hydrogeologial situation is far more complex in this area.

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Chloride Levels in Waterloo illustrates how water is drawn to wells regardless of surface topography. Currently watersheds are onlydelineated based on surface topography not draw down influences.http://research.ires.ubc.ca/projects/ISM/include/Torontopdfs/Stone_ISM_May2008.pdf

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Topography does not prevent aquifer connectivity as shown in thiscross section of Waterloo Moraine. Clay is not impervious either: Itonly slows rate of infiltration. Our wells still recharge in spite of clay.

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Modflow has its flaws: Use more geologyMany hydrology firms use Modflow programs to studyaquifers but the program assumes aquifers are self containedand this poses a risk.Data input is often subjective which is why mandatory testingstandards and methods are needed to clarify processes toexplain where the numbers came from and how they came tothe results. Make sure the data being used is current.Modflow works better when supported with localizedgeological data including sediment type to better understandactual hydrological connectivity.

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Bore Hole Data isnt Enough!Often times bore hole testing does not go deep enough tomonitor for potential impacts to aquifer systems and holes aretoo widely spaced.Test times often fails to have regard for seasonal variantsincluding spring thaw data and with climate change, year toyear modeling is needed to properly assess delta water levelsbecause trends from one year no longer apply to the followingyear. Trends in Waterloo Region Weather station indicatedrought year/ flood year scenariosUsing bore hole data, outwash till formations can appear toreflect consistent clay coverage but this poses a serious risk toaquifer systems.Ground Penetrating radar profiles can help mitigate the risks byillustrating the sediment distribution of outwash till areas

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Example: The Arkell Research Station in Guelph • Using standard bore hole testing, this area appears to be covered in a consistent clay layer. • GPR profiles identifies this area as a shallow outwash aquifer. The clay is discontinuous. They are like shingles with many spaces of infiltration in between. • This area gathers up to 7% of Guelph’s potable water supply and it recharges cold water trout streams. • The GPR profiles for the Arkell Research Station were provided by the Canadian Geological Survey of Canada.

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International Joint CommissionIt is clear that human and ecosystem healthin the Great Lakes basin cannot be protectedwithout protecting ground-water resources. http://www.ijc.org/rel/news/2011/110308_e.htm

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REGARDING ENGINEERING FIRMSThere is no money in discovering bad geology...or is there?

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Problems With Engineering Firms Engineering firms are not held liable for their work in creatingenvironmental impact studies after theyve signed off on it. Therisk transfers to the firm who purchased their data. If issuesarise due to poor environmental studies, they are not heldliable for any of the the work they did.Firms like this stand to profit from remediation if things do gowrong. There is no reasonable incentive for engineering firmsto do a the job right to prevent long term risks. Rubber Stamps are not enough. If there is a lack of fiscal accountability there is no guarantee of good work!

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Engineering Firms Continued:Studies for this Nuclear Power Storage facility appear tobe limited to a rather specific layer where the boreholeswere lucky enough to go through some solid chunks. Arefindings consistent with alternative geological data?(Geologic Survey of Canada, USGS etc.)Currently there is no mandatory criteria for whatconstitutes as a reasonable test times or methods tosecure best management practices are reasonablyapplied. Are test times and methods used reasonable ordo they reflect biased, outdated data and/or unclearformulas? Will this data be peer reviewed?

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If monitoring and peer review data costs extra hold industry accountable to those costs. Place a levy on these firms to cover for additional costs associated with long term independent monitoring as a way to protect the public interest. Make them pay for independent peer reviewed studies to make sure the science they are using is reasonable. Hold Engineering firms accountable for the work they produce by holding a check worth the value of their services. If problems happen as a result of a blatantly poor environmental assessment, cash that check!

26.
Highland Mega-Quarry Proposal factsProposed project size: 2,316 acresWidth: 5kmAmount of rock reserved: 1,000,000,000 tonnesDepth of Quarry below water table: 200 feetWater to be pumped per day: 600,000,000 litresOver 500 wells will be working in perpetuity to re-inject water into aquifers under the quarry. Source: In the Hills magazine, Melancthon Mega Quarry by the Numbers by Tim Shuff July 16, 2012 http://www.inthehills.ca/2011/06/back/melancthon-mega-quarry-by-the-numbers

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The Proposed Mega Quarry and Proposed Nuclear Storage both impacted by KARSTMap from a presentation by Dr Derek Ford, Professor Emeritus from McMaster University, Environmental Geography and Geology, February 2012 :http://www.couchconservancy.ca/ONCWebsite/htm/Among%20ourselves.htm

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Regarding MegathrustsThere are fault zones that have severe implicationson the seismic hazard of nuclear facilities located onthem, as well as deep geological waste repositoriesincluding this proposed nuclear storage project.More effort should be undertaken to properly mapthese megathrusts, mainly by processing theavailable seismic data in Lake Huron.

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These cold-joint megathrusts are clearly visible in deep seismicreflection data. The leading one is the Grenville Front (GF) fault, themiddle one is the Central Metasedimentary (CM) fault, and the thirdis the Elzevir (EL) fault.

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The frequency of tornadoes in Ontario is expected toincrease with climate change. Are we planning for it?

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The Biggest Risk of All:Political Interference hampering sound science.Prime Minister Harper mandated 2 year approvalsfor environmental assessments by the CanadianNuclear Safety Commission."There is no analysis or rationale that can be produced by the government to defend the two-year arbitrary time line," Liberal Natural Resources critic David McGuinty

36.
Harper fired Linda KeenSource: CBC NEWS Nuclear safety watchdog head fired for lack of leadership: minister http://www.cbc.ca/news/canada/story/2008/01/16/keen-firing.html When the chief of the Canadian Nuclear Safety Commission suggested that one shouldnt run nuclear plants without necessary safety equipment, she was fired.

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Political Interference Continued:With Bill C-311, the Nuclear Safety Control Actundermined. Environmental assessments will bemoved to the Canadian Nuclear SafetyCommission, which is a licensing body not anassessing body -- so there is a built-in conflict.

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First Solution is to Stop the ProblemWe Must End Nuclear Power Generation and stop generating nuclear wastes.

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There are no guarantee safe storageThere is no moral ethical or scientifically validevidence to show that we can reasonably monitor ormanage the safe disposal of radioactive wastes for10,000 to millions of years.It is unreasonable to assume we could design such a system without flaws or adverse consequences to future generations when current evidence shows systems are failing in less than 100 years at an alarming rate.

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We need guidelines to strictly prohibit the placement ofNuclear storage away from water, food and geological risks.- Prohibit the placement of long term new nuclear storage facilities along the Great Lakes basin to protect these shared water resources and human populations for the long term.- Only 6% of Ontarios land mass is suitable for A1 farming so prohibit placing long term nuclear storage units in proximity to farmlands or their watersheds in order to secure Canadas long term food security.- Designated appropriate storage areas based on low hydrogeological connectivity and assume hydrological fractures exist. The further the distance of the storage units from growth areas and aboriginal communities the better.

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Green Energy is Do-able Now“Renewable energy sources, accessed with commercially available technologies, could adequately supply 80% of total U.S. electricity generation in 2050 while balancing supply and demand at the hourly level.”National Renewable Energy Lab US:http://www.nrel.gov/analysis/re_futures/The expected resource potential of Canada, electricity generated bygeothermal energy could replace approximately 10 nuclear powerplants and provide up to 10% of Canadas current total electricitygeneration.Canadian Geological Surveyhttp://www.globe-net.com/articles/2011/september/16/canada-is-awash-with-clean-geothermal-energy-resources/

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If you think there is a lack of public support for nuclear power today,,,

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In ConclusionTo place long term Nuclear storage in Karst, along aquifers,farmlands, the Great Lakes and fault lines is not reasonable.This area is in proximity to significant seismic risks that willonly be aggregated by the proposed Melancthon Mega Quarryand other subsurface geological changes brought on byprojects such as this.With the unreasonable, non-scientific 2 year deadline forapprovals, as mandated by Harper Government, its notreasonable to assume such a short review period can securethe prevention of long term ecological, sociological oreconomic risks associated with this proposal.

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Conclusion Continued:In the absence of a National Energy Strategy, it is premature tocommit Ontario taxpayer dollars to a venture like this whenthere is no proven need or proven plan in place to show thatthis project is economically feasible or beneficial for theprovince over the long term.Data shows cheaper, cleaner energy options exist that createmore jobs and more economic prosperity for residents. This isoutlined in numerous reports including Tide Canadas A NewEnergy Vision for Canada found online here: http://tidescanada.org/energy/newenergy/Why are we spending so much in tax payer dollars supportinga private firm using an antiquated system of energy supply thatbinds Canadians to have to store toxic wastes in perpetuity? Itis not reasonable. Time to simply cut bait and drop nuclear. Itscheaper in the long run.